ML20206M819

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Forwards Comments on 860620 Draft Low Power License NPF-56 & List of Unresolved Items
ML20206M819
Person / Time
Site: Seabrook NextEra Energy icon.png
Issue date: 06/26/1986
From: Devincentis J
PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To: Novak T
Office of Nuclear Reactor Regulation
References
SBN-1145, NUDOCS 8607010295
Download: ML20206M819 (8)


Text

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SEABROOK STATION Engineering Office l

I Public Service of New Hampshire June 26, 1986 NEW HAMPSHIRE YANKEE DIVISION S BN-114 5 T.F.

B7.1.2 United States Nuclear Regulatory Commission Washington, DC 20555 Attention:

Mr. Thomas M. Novak, Acting Director Division of PWR Licensing-A

References:

(a) Construction Permits CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 (b) USNRC Letter, dated June 20, 1986, " Draft License for Seabrook Station, Unit 1", T. M. Novak to R. J. Harrison Subj ect :

Comments to Draf t License for Seabrook Station, Unit 1

Dear Sir:

In Reference (b), you transmitted a Draf t Low Power License, No.

NPF-56, for Seabrook Station, Unit 1 and a list of items which had not been resolved as of June 20, 1986. Your letter also requested written comments to those enclosures.

Therefore, enclosed please find our comments to the Draf t Low Power License (Enclosure 1) and to those ur/-

resolved items (Enclosure 2) which you had identified.

Very truly yours,

.// A C John DeVincentis Director of Engineering Enclosures cc:

Atomic Safety and Licensing Board Service List i

8607010295 860626 A nh

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PDR ADOCK 05000443 A

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l Seabrook Station Construction Field Office. P.O. Box 700. Seabrook, NH O3874

Diana Curran, Esquire Patar J. Mathews, Mayor Harmon & Weica City Hall 2001 S. Strsst, N.W.

N:wburyport, MA 01950 Suite 430 Washington, D.C.

20009 Judith H. Mizner Silvergate, Gertner, Baker, Sherwin E. Turk, Esq.

Fine, Good & Mizner Office of the Executive Legal Director 88 Broad Street U.S. Nuclear Regulatory Commission Boston, MA 02110 Tenth Floor Washington, DC 20555 Calvin A. Canney City Manager Robert A. Backus, Esquire City Hall 116 Lowell Street 126 Daniel Street P.O. Box 516 Portsmouth, NH 03801 Manchester, NH 03105 Stephen E. Merrill, Esquire Philip Ahrens, Esquire Attorney General Assistant Attorney General George Dana Bisbee, Esquire Department of The Attorney General Assistant Attorney General Statehouse Station #6 Office of the Attorney General Augusta, ME 04333 25 Capitol Street I

Concord, NH 03301-6397 Mrs. Sandra Gavutis Chairman, Board of Selectmen Mr. J. P. Nadeau RFD 1 - Box 1154 Selectmen's Office Kennsington, NH 03827 10 Central Road Rye, NH 03870 Carol S. Sneider, Esquire Assistant Attorney General Mr. Angie Machiros Department of the Attorney General Chairman of the Board of Selectmen One Ashburton Place,19th Floor Town of Newbury Boston, MA 02108 Newbury, MA 01950 Senator Gordon J. Humphrey Mr. William S. Lord U.S. Senate Board of Selectmen Washington, DC 20510 Town Hall - Friend Street (ATTN: Tom Burack)

Amesbury, MA 01913 Richard A. Hampe, Esq.

Hampe and McNicholas Senator Gordon J. Humphrey 35 Pleasant Street 1 Pillsbury Street Concord, NH 03301 Concord, NH 03301 (ATTN: Herb Boynton)

Thomas F. Powers, III H. Joseph Flynn, Esquire Town Manager Office of General Counsel Town of Exeter 10 Front Street Federal Emergency Management Agency 500 C Street, SW Exeter, NH 03833 Washington, DC 20472 Brentwood Board of Selectmen Paul McEachern, Esquire RFD Dalton Road Matthew T. Brock, Esquire Brentwood, NH 03833 Shaines & McEachern Gary W. Holmes, Esq.

25 Maplewood Avenue Holmes & Ells P.O. Box 360 47 Winnacunnet Road Portsmouth, NH 03801 Htmpton, NH 03842 Robert Carrigg Mr. Ed Thomas Town Office FEMA Region 1 Atlantic Avenue 442 John W. McCormack PO & Courthouse North Hampton, NH 03862 Boston, MA 02109 Y

Administrative Judge Helen Hoyt, Chairperson Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Administrative Judge Sheldon J. Volfe, Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Eameth A. Luebke Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission L*ashington, D.C. 20555 Dr. Jerry Harbour Atomic Safety and Licensing Board Panel U.S. Nuc1 car Regulatory Commission Washington, D.C. 20555 a

ENCLOSURE 1 TO SBN-1145 COMMENTS TO DRAFT LICENSE NO. NPF-56 PAGE ITEM COMMENT 2

1.H Conditions for protection of the environment set forth in the Environmental Protection Plan were not provided.

Appendix B to NPF-56 should be provided for comment considering that the Final Draf t Technical Specifications, ( Appendix A to NPF-56), have been provided for NHY comment.

2 2.B(1)

Should read, "The Licensees acting through Public Service Company of New Hampshire (PSNH) pursuant to..."

2 2.B(3)

Should read, "The Licensees acting through PSNH, pursuant to..."

3 2.B(4)

Should read, "The Licensees acting through PSNil, pursuant to..."

3 2.B(5)

Should read, "The Licensees acting through PSNH, i

pursuant to..."

3 2.B(6)

Should read, "The Licensees acting through PSNH, pursuant to..."

3 2.C(l)

Should read, "The Licensees acting through Public Service Company of New Hampshire are authorized to..."

3 2.C(2)

Environmental Protection Plan contained in Appendix. B should be made available for comment.

Second sentence should read, "The Licensees acting through PSNH shall operate..."

4 2.C(3) &

Should read, "The Licensees acting through PSNH 2.C(4) should..."

4 2.C(4)

The Fire Protection Program condition should be removed from Section 2.C of the License as an

" additional condition" and should be made a

" stand alone" item under Section 7 of the license, similar to the " stand alone" finding 2.E for the Seabrook Station Physical Security Plan.

The Fire Protection Program should be dealt with in a similar manner as the Physical Security Plan.

This " stand alone" fire protection issue could be placed as Item 2.11 of the License, and it would heighten visability to our commitment to the Fire Protection Program.

ENCLOSURE 1 TO SBN-1145 (Continued)

COMMENTS TO DRAFT LICENSE NO. NPF-56 PAGE ITEM COMMENT 4

2.C(5)

This should not be a license condition because the Staff has approved Seabrook Station's Hot OPS experience in SSER 4.

Addi t ionally,

should the Staff deem this necessary as a license condition, it should not be con 9idered a condition for a Low Power License. This condition should only be considered when in Mode 1, which is the only time one is authorized for 20% power.

This license doesn't allow operation above 5% power, so why should a condition exist if we are already restricted.

5 2.C(8)

This should not be a license condition.

We will provide a letter by June 27, 1986 summarizing all of our responses and commitments to Generic Letter 83-28, which had been addressed through previous correspondence.

Our letter addresses each implementation requirement and indicates how Seabrook has met the requirements (e.g.,

develop procedures) and/or provided an adequate schedule for implementing those requirements (e.g., assessment programs).

5 2.C(9)

The condition should read " Prior to restart following the first refueling outage, the Licensees acting through PSNH shall have operational a Safety Parameter Display System as described by their FSAR, and shall include those modifications as described in their submittals dated January 6, 1986 and April 2, 1986".

5 2.D Should read, "The Licensees are exempted from..."

6 2.E Should read, "The Licensees shall fully f uple-ment and maintain..."

6 2.E Line 5 has inadvertently omitted a referenced section of 10CFR. 6 2.E The latest revision of the Physical Security Plan, transmitted June 16, 1986, should be referenced.

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ENCLOSURE 1 TO SBN-ll45 (Continued)

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COMMENTS TO DRAFT LICENSE NO. NPF-56 1

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PAGE ITEM COMMENT t

6 2.F Should read, "Except as otherwise provided in the Technical Specifications or Environmental i

Protection Plan, the Licensees shall..."

l 6

The license should have an indication as to i

the effective date and expiration date.

The expiration date should be 40 years af ter the l

issuance date as requested by PSNH Letter l

(SBN-ll42), dated June 25, 1986.

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ENCLOSURE 2 TO SBN-1145 i

COMMENTS TO LIST OF UNRESOLVED ITEMS i

ITEM DESCRIPTION COMHENT 1

Radiation Data In a PSNH Letter (SBN-1093), dated June 5, Management 1986, we addressed this concern and provided System adequate justification for existing fuse (SSER 5-7.5.2.2) assemblies, but have committed to upgrade the fuse assemblies as described in that letter and agreed upon by the Staf f.

Therefore, we feel this item has been adequately addressed and should be removed from consideration as a license condition.

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Fire Protection In a PSNH Letter (SBN-970), dated March (SSER 5-9.5.1.4) 18, 1986, we transmitted our deviation to providing a filter suppression system based upon analysis which determined that temper-l atures which could cause a fire could not be attained.

A copy of the analysis has been provided to members of the Staff through our 4

Bethesda office.

Recently, your Staff re-quested further justification to support our analysis, and we intend to provide that as soon as possible.

3 Solid Waste In a PSNH Letter (SBN-ll21), dated June 17, Management 1986, we transmitted the additional infor-l System mation requested by the Staff regarding the (SSER 5-11.4.2) spill control methods of the waste solidi-fication system. Therefore, we feel this item has been adequately addressed and 4

should be removed from consideration as a i

license condition.

4 TMI Action Plan In a PSNH Letter (SBN-1063), dated May 20, l

Item II.F.1, 1986, we provided further information re-Accident garding this issue.

After further dis-Monitoring cussions with the Staf f, we will demon-i Instrumentation strate following the first refueling outage, (SSER 5-11.5.2) that the iodine / particulate sampling system l

adequately represents the radioactive iodine and particulate samples obtained.

.~_

ENCLOSURE 2 TO SBN-1145 (Continued)

COMMENTS TO LIST OF UNRESOLVED ITEMS ITEM DESCRIPTION COMMENT 4

5 leakage Reduction In PSNH Letters (SBN-1106, -1124, -1125),

Measurement Program dated June 11, 18, and 20, 1986, respec-(SSER 5-15.9.15) tively, we provided sufficient information and commitment to show that the Seabrook Station's Leakage Reduction Program has successfully established its goals and guidelines for implementation. Therefore, we feel this item has been adequately 1

addressed and should be removed f rom con-sideration as a license condition.

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